The complaint was filed in the U.S. District Court for the Southern District of New York. It names as defendants the Metropolitan Life Insurance Company and the Metropolitan Life Insurance Company Employee Benefits Committee. Â

According to plaintiffs, MetLife is failing to pay the full promised value of alternative benefits available under its Metropolitan Life Retirement Plan. The complaint suggests MetLife is failing to meet its obligations to ensure different annuity options under the plan are actuarially equivalent to the planâs default benefit, as required under ERISA and the terms of the plan itself.

According to the complaint, MetLife sponsors the plan for its eligible employees and the eligible employees of certain participating affiliates. The plan transitioned from a traditional defined benefit plan to a cash balance benefit plan effective January 1, 2002. All new hires after December 31, 2002, were automatically enrolled in the cash balance benefit planâreferred to in the complaint as the âCurrent Planââwhile employees hired before December 31, 2002, had to choose between moving to the cash balance plan or remaining grandfathered in the preexisting defined benefit plan, i.e., the âTraditional Plan.â

The argumentation in the complaint considers the topic of the âactuarial equivalenceâ of different types of annuity benefits to be paid under the current and former plan designsâin particular, it questions the method of calculation of joint/survivor annuity benefit payments as compared with single annuity benefit payments.

According to the complaint, to convert a retireeâs default annuity benefit into an alternate annuity benefit (such as a joint/survivor annuity), the present value of the aggregate (i.e., total) future benefits that the participant (and, if applicable, the beneficiary) is expected to receive under both the default benefit and the alternate annuity benefit must be determined. The present values are then compared to determine the conversion factor. There are two main components of these present value calculations: an interest rate and a mortality table.

The argument continues as follows: âThe plan specifies the actuarial assumptions used to calculate the conversion factor (and thus the value of the alternate annuity benefits). Specifically, in terms of a mortality table, the plan uses the 1971 Group Annuity Mortality Table for Males (the 1971 GAM table), set back one year for participants or former participants and set back five years for beneficiaries. The 1971 GAM table was developed over 45 years ago, when people had much shorter life expectancies.â

According to the complaint, Metropolitanâs use of the 1971 GAM mortality table âis inherently unreasonable because of its outdated accelerated mortality rates.â

âThe plan also uses a 6 percent interest rate,â the complaint says. âThe combined result of using a 6% interest rate and the 1971 GAM mortality table is that defendants do not provide actuarially equivalent alternate annuity benefits, but instead provide alternate annuity benefits that are materially lower than the benefits that would be a true equivalent to default benefits. Accordingly, defendants caused plaintiffs and class members to unknowingly forfeit and lose part of their vested benefits due under the terms of the plan.â

The complaint goes on to argue that defendants have violated ERISAâs anti-forfeiture rule and caused plaintiffs and other participants and beneficiaries of the plan injury âevery month.â

âPlaintiffs accordingly seek an order from the court reforming the plan to conform to ERISA, payment of future benefits in accordance with the reformed plan as required under ERISA, payment of amounts improperly withheld, and such other relief as the court determines to be just and equitable,â the complaint says.